Hospital Corporation of America and Subsidiaries - Page 22

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          448(d)(7)(C) attempt to fill the gaps by requiring both hospital            
          and nonhospital businesses that either cease to engage in the               
          trade or business to which a section 481(a) adjustment relates or           
          terminate existence prior to the end of the spread period to take           
          into account in the year of cessation or termination any                    
          remaining portion of the section 481(a) adjustment.  Under such             
          circumstances, the Chevron rule prevents us from substituting our           
          own construction of section 448 if the Commissioner's                       
          interpretation is reasonable.  Peoples Fed. Sav. & Loan                     
          Association v. Commissioner, 948 F.2d at 300.                               
          Are the Regulations Valid?                                                  
               Final regulations interpreting section 448(d)(7)(C) are                
          provided in section 1.448-1(g), Income Tax Regs.10  The final               

          9  (...continued)                                                           
          change pursuant to the provisions of secs. 1.446-1(e)(3) and                
          1.481-5, Income Tax Regs., that would prevent a taxpayer from               
          escaping forever taxation upon income previously deferred under             
          the hybrid method.                                                          
          10  Sec. 1.448-1(g), Income Tax Regs., provides in pertinent                
          part as follows:                                                            
                    (g) Treatment of accounting method change and                     
               timing rules for section 481(a) adjustment--(1)                        
               Treatment of change in accounting method.   * * *                      
                    (2) Timing rules for section 481(a) adjustment--(i) In            
               general.  Except as otherwise provided in paragraphs                   
               (g)(2)(ii) and (g)(3) of this section, a taxpayer required             
               by this section to change from the cash method must take the           
               section 481(a) adjustment into account ratably (beginning              
               with the year of change) over the shorter of--                         
                         (A) The number of taxable years the                          
                                                             (continued...)           




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